ML20081B564

Application for Amend 10 to License NPF-15,revising Tech Spec 4.8.1.1.2.C to Determine Operability of Diesel Generator Should Diesel Fuel Oil Fail to Meet Test for Insolubles & Revising Section 6 Re Organization Changes

ML20081B564
Person / Time
Site:	San Onofre
Issue date:	03/07/1984
From:	Baskin K SOUTHERN CALIFORNIA EDISON CO.
To:
Shared Package
ML13305A539	List: ML20081B564 ML20081B573 ML20081B579 ML20081B591
References
TAC-54698, TAC-54699, TAC-54700, TAC-54701, TAC-61516, TAC-61517, NUDOCS 8403090227
Download: ML20081B564 (10)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA EDISON ) DOCKET NO. 50-362 COMPANY, EI AL. for a Class 103 license to )

Acquire, Possess, and Use a Utilization ) Amendment Application No. 10 Facility as Part of Unit No. 3 of the San )

Onofre Nuclear Generating Station )

SOUTHERN CALIFORNIA EDISON COMPANY, ET AL. pursuant to 10 CFR 50.90, hereby submit Amendment Application No. 10.

This amendment application consists of the following proposed changes to facility Operating License NPF-15:

1. Proposed Change NPT-15-75 is a request to revise Technical Specification 4.8.1.1.2.c to determine the operability of the diesel generator should the diesel fuel oil fail to meet the test for insolubles.

2. Proposed Change NPF-15-83 is a request to revise Section 6, Administrative Controls, to reflect changes in organization structure which will consolidate and increase executive level atte? tion and oversight of all nuclear activities. In addition to revising the structure of the organization and associated review and approval responsibilities, incorporation of new NRC reporting requirements and minor clarification of Section 6 requirements are also included.

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l Pursuant to 10 CFR 170.22, each of the Proposed Changes contained in Amendment Application No.10 is considered to constitute a Class I amendment. i The basis for this determination is that the Proposed Changes contained in Amendment Application No.10 are duplicates of those contained in Amendment Application No. 24 to Operating License NPF-10 for San Onof re Nuclear Generating Station, Unit 2. Based on this determination, a Class I fee of

$400 is required for each of the Proposed Changes contained in Amendment Application No.10. The fee of $800.00 corresponding to this determination is enclosed.

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c.y o DESCRIPTION OF PROPOSED CHANGES NPF-10-75 AND NPF-15-75 AND SAFEfY ANALYSIS This is a request to revise Section 4.8.1.1.2C " Electrical Power Systems Surveillance Requirements" of the Technical Specifications of San Onofre Nuclear Generating Station Units 2 and 3.

Existino Technical Specifications Unit 2 See Attachment A Unit 3 See Attachment C Proposed Technical Specifications

• 4 Unit 2 See Attachment B Unit 3 See Attachment 0 Description Surveillance requirement ASTM-02274-70 tests diesel fuel oil for insolubles and Reg. Cuide 1.137 recommends that diesel generators not be considered inoperable on the basis of this test. However, failure of ASTM-02274-70 currently requires declaring the diesel generator inoperable. ASTM-D2274-70 tests fuel for storage stability and attempts to determine the level of insolubles at some time in the future by accelarated ageing of the fuel.

Therefore, there should be a period of time when the diesel fuel oil will be within the insolubles limits even if the fuel oil fails ASTM-D2274-70. Even if the fuel oil fails this test, there is a considerable period of time before the fuel oil would actually age tc the point where the fuel oil will limit a diesel generator's ability to start and continue to run. Action Statement 3.8.1.1 allows a maximum of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to demonstrate the operability of a diesel generator that has been declared inoperable. If the diesel generator was declared inoperable on the basis of ASTM-02274-70, the old fuel oil must either be replaced or shown to meet the applicable specification. Replacement of fuel oil or retests take longer than seventy-two hours. Therefore, if a diesel genere, tor is declared inoperable based on ASTM-02274-70, then the plant must shut down.

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O _o Although ASTM-D2274-70 is probably the best method currently available for measuring storage stability of fuel oil, it is imprecise with repeatability and reproduceability within 30% and 100% respectively, as stated in the test procedure. (These figures are for insolubles of 1 mg/100 ml or less. No figures are available for the 2 mg/100 ml level of insolubles.) It is '

therefore inappropriate that such an imprecise measurement be used to determine the operability of a diesel generator.

The purpose of these changes is to i: vise surveillance requirements associated with the level of insolubles in the diesel fuel oil to provide actions comensurate with the significance of this test consistent with the recommendations of Reg. Guide 1.137.

Safety Analysis The proposed changes discussed above shall be deemed to constitute a significant hazards consideration if there is a positive finding in any of the following areas.

1. Will operation of the facility in accordance with these proposed changes involve a significant increase in the probability or - a consequences of an accident previously evaluated?

Response: No The diesel generators respond to a loss of cffsite power event to pr', vide electric power to emergency busses. These proposed changes rsvise the surveillance requirements associated with the level of -

insolubles in the diesel fuel oil to allow adequate time (14 days) to demonstratie operability before entering the associated action statement. Higher levels of insolubles present in the diesel fuel oil does not immediately threaten diesel generator operability.

Therefore, the diesel generator will continue to contribute to the mitigation of design bases events and the probability or consequences of an accident previously evaluated remain unchanged.

2. Witi operation of the facility in accordance with these proposed changes create the possibility of a new or different kind of accident from any previously evaluated? \

s Response: No The proposed changes do not change the configuration of the plant or the way in which it is operated. Therefore, these changes do not create the possibility for a new or different kind of accident from any previously evaluated.

3. Will operation of the facility in accordance with these proposed changes involve a significant reduction in a margin of safety?

Response: No

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l The proposed change affects only a surveillance for fuel oil quality which predicts future fuel oil quality. Failure to meet this parameter (insolubles) does not render a Diesel Generator inoperable for the short period allowed by these proposed changes for corrective action to be taken. Since the diesel generators will continue to provide the same degree of protection for the FSAR design bases events, before as well as after the proposed changes, the margin of safety provided by the diesel generators wi~.1 be unchanged.

48 FR 14864 dated April 6, 1983 provided examples of amendments that are not likely to involve a significant hazards consideration. Although this item does not increase the probability or consequences of any previously analyzed accident, it would most likely be considered to be most similar to example (vi) in that the reduction.in technical specification requirements may be

. perceived to insignficantly reduce in some way a safety margin.

' Safety and Significant Hazards Determination Based on the above discussion, Proposed Changes NPF-10-83 and NPF-15-83 do not , .

involve a significant hazards consideration in that it does rot: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a

.significant reduction in a margin of safety. In addition, it is concluded that: (1) there is rease able assurance that the health and safety of the public will not be. endangered by the proposed change; and (2) this action will not result in a condition which significantly alters the impact of the station on the environment as described in the NRC Final Environmental Statement.

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